+353 1 675 3140
enquiries@citytrust.ie

Russian De-Offshorisation Law to Impact Foreign Controlled Companies

December 24th, 2014
he Russian Government is introducing new regulations to its tax code which will have important implications for Russian tax residents (both individuals and business) who are deemed to have controlling interests in foreign companies and entities, or Controlled Foreign Companies (CFCs)

The Russian Government is introducing new regulations to its tax code which will have important implications for Russian tax residents (both individuals and business) who are deemed to have controlling interests in foreign companies and entities, or Controlled Foreign Companies (CFCs). 

The law, signed into act on November 24th, 2014 will come into effect on January 1st 2015. The change in the code holds that foreign companies controlled by tax residents in Russia should pay their taxes in Russia. Initially residents with an over 50% stake in a CFC will be affected by the law. This is only for Thereafter the threshold will be lower, starting in 2016, at a 25% interest.

To ascertain whether the effective place of management of the company is in Russia, the following criteria will be used:
    •    The majority of the board meetings are held in Russia
    •    The company management habitually engages in company related activity in Russia
    •    The company CEO predominantly performs his or her duties in Russia

Important dates:


1 January 2015 - Law comes into force
1 April 2015 - Deadline for notfying Russian tax authorities of controlling interest in CFC’
20 March 2016 – First CFC reporting date

Its important that companies complete an audit of their company structures in order to determine which companies / entities will qualify as CFCs. It is also possible to revise the existing structure of the group based on the expected business, income and tax residency.

For further details please contact our Russia Desk in Dublin on +353 1 675 3140, or email enquiries@citytrust.ie

City Trust and Corporate Services Ltd. is authorised by the Irish Department of Justice and Equality to carry on business as a trust or company

service provider (TCSP) Registered in Ireland, 1st Floor Riverview House, 21/23 City Quay, Dublin 2. Company Reg No. 182760